West Virginia, 217 U. S. 1 (1910), the U.S. Supreme Court again affirmed that Maryland's southern border extended to the low-water mark on the far side of the Potomac River. The issue arose again in 1915, when the Washington Steel & Ordnance Company claimed it owned the newly created land in the Anacostia River created by the dredging operation. The District of Columbia Supreme Court held on December 29, 1915, that the federal government held title to the land. But this decision was overturned on technical grounds by the Court of Appeals for the District of Columbia in Washington Steel & Ordnance Company v. Martin, 45 App. 600 (1917). Nonetheless, in dicta in Washington Steel & Ordnance Company, the court of appeals made note of the Supreme Court's ruling in Morris v. United States and held that the reclaimed land belonged to the federal government. The issue as to who owned the dredged land and islands seemed settled. By 1920, the Corps of Engineers had dropped the dam idea and instead proposed creating a deep lake on one side of the Anacostia River by linking several of the mid-river islands it had built with dikes. That same year, Congress specifically prohibited the Corps from extending Anacostia Park beyond Benning Bridge, which forced the Corps to drop its plans for a drawbridge. In late 1922, dredging temporarily ceased after funding for continued dredging ran out. Early development efforts 1920s–40s In 1926, the National Aeronautic Association proposed filling in all or part of Kingman Lake to expand Kingman Island so that a new city airport could be built there. Two years later, the piers supporting the Benning Bridge were reconfigured to permit a dredge to pass between them. The existing piers (which were apart) were replaced with piers apart. The reconfiguration was exceptionally complex, as 92 percent of the city's electrical supply passed through cables carried by Benning Bridge. The new, large dredging ship Benning was used to dredge the upper part of the Anacostia River, and some of the fill from this operation was used to create two new islands in Kingman Lake, named Island No. 3 ( in size) and Island No. 4 ( in size). In 1934, Benning Bridge was rebuilt as a beam bridge on concrete piers. That same year, the Corps of Engineers transferred ownership of Anacostia Park, Kingman and Heritage islands, and Kingman Lake to the